Client Bill of Rights / Client Letter / Privacy Policy

CLIENT BILL OF RIGHTS

1. We will service you in a prompt, courteous and responsive manner, treat you with individual dignity and respect and give consideration to both your needs and those of your family.

2. We will respect your cultural background and remain conscious of your individual needs in terms of language, ethnicity, religion and gender.

3. We will be sensitive to any special needs that you may have due to a physical or mental disability.

4. We will respect your rights to privacy and all discussions, consultations and records pertaining to your case will be treated confidentially.

5. You have the right to know the identity and professional status of any individuals providing service to you and to know which professional staff member is primarily responsible for providing service to you.

6. You have the right to informed participation in decisions involving your case.

7. You have the right to refuse any treatment or service that is offered to you. We will inform you about the effect a refusal may have on you, such as persistence of symptoms or worsening of your condition, a possible change in our ability to deliver service and so on.

8. If you are a minor, we will obtain your parents’ or guardians’ consent before providing services beyond an assessment.

9. We will provide you with written materials about our services and the cost to you, if any.

10. You have a right to a violence and harassment free environment. Any harassment or violence made towards you or if you display any harassment or violent behavior towards another person will not be tolerated. Those engaged in violent acts on the Agency’s premise will be reported to the proper authorities and fully prosecuted. Services will also terminate.

11. If you feel that any of these rights have been violated, please refer to the grievance procedures as stated in the Client Letter of Understanding.

Catholic Charities of Kansas City-St. Joseph

CLIENT LETTER OF UNDERSTANDING

WELCOME TO CATHOLIC CHARITIES! We hope that our relationship will help to resolve the issues that brought you to us and that you will experience the changes in your life that you are seeking.

Catholic Charities is within the Catholic Diocese of Kansas City-St. Joseph, Missouri and works closely with the Dioceses of Jefferson City and Springfield-Cape Girardeau. Since 1927, when it was known as the Catholic Welfare Bureau, it has offered its services to anyone in need, regardless of race, ethnic origin, sex, religion, or disabilities. Our service area covers the northwestern portion of the state of Missouri, including the population environs of Kansas City, St. Joseph, Warrensburg, Jefferson City and Springfield.

Mission: As the organization at the service of charity of the Bishop and Church of Kansas City – St. Joseph, the mission of Catholic Charities is to answer the commandment of Jesus Christ to love through service, advocacy, and empowerment of the vulnerable and those in need throughout northern and western Missouri.

Thus the serving role is a primary element of the mission of Catholic Charities. In addition to its service and witness role, Catholic Charities has the equally important prophetic role. That is, it speaks out on social issues on behalf of the powerless within the society, and it is active in proposing or supporting initiatives in society which can lessen human suffering.

As an integral element of the Catholic Church’s ministry to the people of northwestern Missouri, it is important to note that we are bound to support the teachings of the Church with respect to all of the services that we provide. Hence, because of our belief in the sanctity of life, we do not provide any information or in any way condone abortions as a means of terminating a pregnancy.

Range of Service: Catholic Charities, through offices in Kansas City, St. Joseph, and Warrensburg, Missouri, offers the following services:

Support and Education Services

Adoption

Children and Families

Financial Literacy

Disability and Deaf Services

Workforce Development Services

General Workforce

Veteran Employment

Senior Employment

Community Housing Services

Permanent Housing

Housing Development

Bishop Boland Institute for Housing and Community Development

Residential Service Coordination

Supportive Housing for Veteran Families

In home Services

Welcome Center

Emergency Assistance

Single Point of Entry

Case Management Services

Eligibility Requirements: Services are available regardless of race, ethnic origin, sex, religion, or disabilities. The Agency will provide services to minors who are seeking services and are without the consent of their parents or legal guardian, only for a short assessment period. Requirements for each program vary as to factors such as residence location, income status, and age. The programs of the Agency serve people throughout the Dioceses, and even clients who live in areas outside the Dioceses. Certain programs are limited by funding or legal requirements to specific cities, counties, etc. These residency requirements are subject to governmental change; therefore, you should call for a specific service and see if it can be offered to you.

Hours of Service: Our office hours are from 8:00 to 5:30 p.m., Monday through Thursday. The offices are closed on Fridays. Clients are also seen after hours or on weekends by appointment. Our phones have confidential voicemail so you can leave a message after hours. Based upon the type of service, workers are available 24 hours a day 7 days a week by cell phone. In case of an emergency, please call 911.

Client Grievance Procedure: We want your relationship with us to be a satisfying one. If problems arise with the service or with your worker, you may take the following steps to let us know about the problem and give us an opportunity to resolve it with you: (1) If the problem is with the service or some policy or procedure, first bring the matter to the attention of your worker. (2) If the worker cannot resolve the matter or if the difficulty is with the worker, you should then contact the worker’s supervisor. (3) If you still have not gotten satisfaction, you can then deal directly with the Program Director. (4) If you, the worker, the supervisor and program manager cannot reach a satisfactory solution, then you should approach the Chief Operating Officer- Sunny Jones (5) In the event that you do not receive satisfaction at any of the before mentioned levels, you can approach the Chief Executive Officer, Chris Ice.. It is the right of the client to file a grievance without interference or retaliation [COA CR 3]

Client Satisfaction Evaluation: Along with the grievance procedures described earlier, it is important for us to know how well we served each of our clients. Sometime during the course of your relationship with Catholic Charities, or at the end of your service period, you will receive a Client Satisfaction Evaluation Form. When you have received this please forward it to the applicable office in a provided envelope. This will help us to continue to improve the quality and effectiveness of our services. Thank you for your cooperation and assistance in this evaluation process.

Infectious Disease: If you or your child has an infectious disease, this information should be shared with your intake worker. Such information is to be shared under two basic guidelines: the best interest of the client in their need for medical care and treatment, and to safeguard the health and safety of the persons who will be caring for the client.

Client Confidentiality: Client information is kept strictly confidential in accordance with the Agency’s privacy practices. Client health and medical information is only released with the specific written authorization by the client, or as provided in the Agency’s current Notice of Privacy Practices. You may obtain a copy of this Notice from the Agency by accessing its website at www.catholiccharities-kcsj.org, by contacting the Agency and requesting that a copy be sent to you in the mail or by e-mail, or asking for one at the time of your next appointment.

If you request health or medical information from your case that your worker believes is harmful to you or others, your request will be reviewed by the Chief Executive Officer of Catholic Charities to determine whether the information can be released. All requests must be in writing, and you generally must have the written authorization of the Chief Executive Officer to review your records. If your case contains information about more than one client, written authorization from the other client is needed. You always have the right to insert information or statements into your record. Regarding clients who are minors, their legal guardians or parents, need the written permission of the Chief Executive Officer to directly access their records.

Fee Policy: The specific fees vary if applicable from program to program depending on the type of service provided. The details of the fee and payment procedures, for a particular service, are covered during the initial session. It is important to the Agency that your fee amount and payment schedule are clear to you at the start of your service program.

Service Plan: Shortly after your services begin, your worker will involve you in developing a service plan to define the course of action that will be followed in your case. Factors in the service plan include your perception of the current problem and goals for treatment.

Termination of Service: If you need additional services upon termination of services from Catholic Charities, we will make an appropriate referral prior to termination. Also, regardless of the reason for termination of service, you may always request reinstatement of services if you feel it is necessary. Should your caseworker leave the Agency arrangements will be made for the transfer of your case to another worker.

Client Conduct and Obligation: It is understood that the client will actively cooperate in the accomplishment of the goals that are established in the service plan. Failure to cooperate or any misconduct that is contrary to the accomplishment of these goals may be cause for termination of service.

Behavior Support Management Philosophy:

It is the policy of Catholic Charities to follow Catholic Social Teaching and acknowledge social work principles in the management of client behavior in cases where behavior management is indicated. In all cases the use of corporal punishment, manual or mechanical or chemical restraint, aversive stimuli such as electric shock, isolation or locked seclusion, withholding nutrition or hydration, inflicting physical or psychological pain, forced physical exercise to eliminate behavior, punitive work assignments, punishment by peers, and group punishment or discipline for individual behavior is prohibited.

The Agency’s philosophy regarding developing and supporting positive behaviors include developing a positive relationship with the client, build on client’s strengths when initiating services, reinforce positive behaviors, and responds consistently to all incidents of harassment or violence. The Agency may also use appropriate de-escalation interventions which may include: communication techniques including mediation, reflective listening, appropriate feedback, negotiation, non-verbal techniques, assisting the client in regaining control of the situation, separation from the client if necessary, and contacting proper authorities if needed. In the event that behavioral support and management techniques are utilized with a client, the agency will document the interventions used in the client’s case file. Applicable state laws and regulations will be observed at all times.

Health Information

It is the goal of Catholic Charities to ensure that we protect your health information. Timely, accurate, and complete health information from your case record (which includes personally identifiable information about you such as your name, address, phone number, SS#, your diagnosis and treatment) must be collected, maintained, and made available to members of the agency’s service team so that your needs can accurately be served. Most clients understand and have no objections to this use of their health information.

On the other hand, clients may not be aware of the fact that the health information in their case record may also be used in certain circumstances as:

A legal document describing the care rendered.

Verification of services for which the client or a third-party payer is billed.

A tool in evaluating your care for quality improvement.

A tool in educating health professionals for quality improvement.

A source of data for research.

A source of information for tracking disease so that public health officials can manage and improve the health of the nation.

A source of data for agency planning and program marketing.

Examples of How We May Use Your Information

Treatment: Information obtained by your service provider will be recorded in your case record and used to determine the course of treatment and services that should work best for you. When a team of individuals are involved in your service delivery, we will share certain agreed upon components of your record. This is to ensure that the team can best meet your needs.

Payment: A bill may be sent to you or a third-party payer i.e. an insurance company or a funder for a program. The information on or accompanying the bill may include information that identifies you, as well as your diagnosis (if applicable), procedures, and supplies used.

Agency operations: Designated members of the staff may review information in your case record to assess the care and outcomes in your case and others like it. This information will then be used in an effort to improve the quality and effectiveness of the services we provide.

The supervisor of your service provider may review your case record as part of the supervisory process of the agency to ensure that your needs are being met and that agency policy and procedures are being followed.

Third party services: There are some services provided in our organization through contracts with third parties. Examples include vendors, our auditors, our accrediting body, and other contract monitoring bodies. When these services are contracted, information in your case record may be disclosed to them so that they can perform the job we have asked them to do, or they may have incidental access to information in your case record due to the proximity of case record information to their work. These agreements also include any observers or students that are in our organization for educational purposes.

Notifying others: We may use or disclose information to notify or assist in notifying a family member, personal representative, or another person responsible for your care, your location, and general condition.

Abuse or Neglect: We may disclose information from your case record to a public authority that is authorized by law to receive reports of child or elder abuse or neglect. In addition, we may disclose information from your case record if we believe that you have been a victim of abuse, neglect, or domestic violence to the governmental entity or agency authorized to receive such information. In this case, the disclosure will be made consistent with the requirements of applicable federal and state laws.

Law enforcement: We may disclose information from your record for law enforcement purposes as authorized or required by law.

Federal law makes provision for information from your record to be released to an appropriate health oversight agency, public health authority or attorney, provided that a work force member or business associate believes in good faith that we have engaged in unlawful conduct or have otherwise violated professional or clinical standards and are potentially endangering one or more patients, workers or the public. We may also disclose information from your record to a federal or state governmental agency that is responsible for oversight of the health care system or government benefit programs (such as Medicare or Medicaid) for purposes of audits, investigations, inspections, civil or criminal proceedings and other oversight activities.

Judicial and Administrative Proceedings: We may disclose information from your record pursuant to a court order, subpoena, discovery request or other lawful process in the course of any judicial or administrative proceeding.

If you receive services from a Catholic Charities program or department that is subject to the requirements of the Health Information Portability and Accountability Act of 1996 (HIPAA), we will provide you additional information about our privacy practices and your rights under HIPAA.

Donations: Donations to the agency may be sent to Catholic Charities of Kansas City-St. Joseph, Inc. 4001 Blue Parkway Suite 250, Kansas City, Missouri 64130. Should you choose to designate a contribution to a specific program please do so by stipulating that request in writing to the Chief Executive Officer. Please do not give any donation directly to an agency staff member.

NOTICE OF PRIVACY PRACTICES

THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY!

It is the goal of Catholic Charities to ensure that we protect your health information as required by law. Timely, accurate, and complete health information from your case record (which includes personally identifiable information about you such as your name, address, phone number, SS#, your diagnosis and treatment) must be collected, maintained, and made available to members of the agency’s service team so that your needs can accurately be served. Most clients understand and have no objections to this use of their health information.

On the other hand, clients may not be aware of the fact that the health information in their case record may also be used in certain circumstances as:

A legal document describing the care rendered.

Verification of services for which the client or a third-party payer is billed.

A tool in evaluating your care for quality improvement.

A tool in educating health professionals for quality improvement.

A source of data for research.

A source of information for tracking disease so that public health officials can manage and improve the health of the nation.

A source of data for agency planning and program marketing.

Although clients trust their service providers to maintain the privacy of the information in their case record, increasingly, clients want to be informed about what information is collected and to have some control over how their information is used. With this in mind, the federal government enacted the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) requiring that we as a service provider furnish you with our Notice of Privacy Practices. To the extent state laws are more stringent than HIPAA, Catholic Charities will abide by the more stringent state laws when applicable.

This notice describes how protected health information about you may be used and disclosed, including how we may use and disclose your protected health information to carry out treatment, payment, or health care operations and for other purposes that are permitted or required by law. This notice also describes your rights to access and control your protected health information and how you can get access to this information. Please review this notice carefully. If you have any questions about this notice, please contact our Privacy Contact listed at the end of this document. “Protected health information” is information about you, including demographic information, that may identify you and that relates to your past, present or future physical or mental health or condition and related health care services.

NOTE: Effective August 17, 2015, Catholic Charities has elected to become a hybrid entity for purposes of HIPAA. As a hybrid entity, only the departments and programs designated as health care components by Catholic Charities must comply with HIPAA. As a result of the hybrid entity election, this notice applies only to Catholic Charities’ provision of services through its health care components. The following programs are the health care components of Catholic Charities:

Mental Health Counseling

Senior Care Services In-Home Care

Accounting Department (limited to employees whose positions require access to protected health information created or received by the above-designated programs and departments, which are currently the AR/Cash Receipt Specialist, Controller, and Grant Accountant)

We are required to abide by the terms of this Notice of Privacy Practices. We may change the terms of our notice at any time. The new notice will be effective for all protected health information that we maintain at that time. Upon your request, you may obtain any revised Notice of Privacy Practices by accessing our website, www.catholiccharities-kcsj.org, by contacting the agency and requesting that a revised copy be sent to you in the mail or by e-mail, or asking for one at the time of your next appointment. However, a Notice will not be sent by e-mail unless specifically requested by you, along with the specific e-mail address to which the Notice may be sent.

As indicated above, this notice describes how protected health information about you may be used and disclosed and how you can get access to this information. Please review it carefully.We will not use or disclose protected health information from your case record without your authorization, except as described in this notice.

Understanding Your Case Record/Information

Each time Catholic Charities provides a service, information is added to your case record. Among other things, this information serves as a:

Basis for planning your care, services and treatment

Means of communication among the professionals who contribute to your care

Legal document describing the care you received

Means by which you or a third-party payer can verify that services billed were actually provided

A tool in educating heath professionals

A source of data for research

A source of information for public health officials charged with improving the health of the nation

A source of data for planning and program marketing

A tool with which we can work to improve the care you receive and the outcomes we achieve

Understanding what is in your record and how your information is used helps you to:

Ensure it is accurate.

Better understand who, what, when, where, and why others may have access to information about you.

Make more informed decisions when authorizing the release of your information to others.

Your Information Rights:

Although your case record is the physical property of Catholic Charities, the information belongs to you. You have the right to:

Request a restriction on certain uses and disclosures of your information as provided by 45 CFR 164.522. You have the right to request a restriction or limitation of how we use or disclose your protected health information for treatment, payment, or health care operations. For example, you may request that we not disclose information about a prior treatment to a family member or friend who may be involved in your care or payment for care. Your request must be made in writing. Except as noted below, we are not required to agree to your request if we feel it is in your best interest to use or disclose that particular information. However, if we do agree, we will comply with your request unless that information is needed for emergency treatment. We must agree to a requested restriction if (i) it restricts disclosures of your protected health information to a health plan for purposes of payment or health care operations (as opposed to treatment) and (ii) the protected health information subject to the restriction relates solely to a health care item or service for which we (or another health care provider) have been paid out of pocket in full.

Obtain a paper copy of the Notice of Privacy Practices upon request as set forth above.

Inspect and obtain a copy of your case record as provided for in 45 CFR 164.524. Generally, this allows you the right to inspect and copy the protected health information that we maintain about you in our designated record set for as long as we maintain that information. This designated record set includes your medical and billing records, as well as any other records we use for making health care or medical decisions about you. If we maintain an electronic health record of your protected health information, you have the right to obtain a copy of any protected health information comprising such electronic health record in electronic format and to direct us to transmit such electronic copy of your protected health information to another designated entity or person so long as your designation is clear, conspicuous and specific. For this purpose, “electronic health record” means an electronic record of your protected health information that is created, gathered, managed and consulted by us or by one or more of your other health care providers if it was delivered to us. Any psychotherapy notes that may be included in your records are not available for your inspection or copying by law. There are situations where we may deny you access to your records. In such situations, we would inform you of our reasons for denial and you would have the right to have this denial reviewed. We may charge you a fee for the costs of copying, mailing, or other supplies used in fulfilling your request. If you request an electronic copy of your electronic health record, we may charge you our reasonable labor costs incurred to comply with your request.

Amend your case record as provided in 45 CFR 164.528. You have the right to request that we amend your protected health information if you feel that it is incomplete or inaccurate. You must make this request in writing, stating exactly what information is incomplete or inaccurate and the reasoning that supports your request. We are permitted to deny your request if it is not in writing or does not include a reason to support the request. We may also deny your request if under the following conditions: (i) we did not create the information or the person who created it is no longer available to make the amendment; (ii) the information is not part of the record which you are permitted to inspect and copy; (iii) the information is not part of the designated record set kept by us; or (iv) if in our opinion the information is accurate and complete.

Obtain an accounting of disclosures of information from your case record as provided in 45 CFR 164.528. You have the right to request an accounting of the disclosures of your protected health information we have made for up to six years prior to your request. However, the accounting will not include any disclosures of your protected health information: (i) to carry out treatment, payment or health care operations; (ii) to you or your personal representative; (iii) incident to a use permitted or required by law; (iv) pursuant to your written authorization; (v) to persons involved in your care; (vi) for national security or intelligence purposes; (vii) to correctional institutions; or (viii) from which all of your identifying information has been removed in accordance with applicable law. Your request for an accounting must be in writing and state the time period for which an accounting is requested. The first accounting you request in any 12-month period will be free of charge. We may charge you a reasonable and cost-based fee for copying and postage for any subsequent request for an accounting during the same period.

Request communications of information from your case record by alternative means or at alternative locations. For example, you may request that we send communications to you regarding your protected health information to a work address or via e-mail. Your request must be in writing. We will honor all reasonable requests, but may condition approval on you providing an alternative address or contact method, and information on how payment will be handled.

Revoke your authorization to use or disclose health information except to the extent that action has already been taken as described below.

The Responsibilities of Catholic Charities:

This organization is required to:

Maintain the privacy of information in your case record.

Provide you with a copy of our Notice of Privacy Practices.

Notify you and other affected individuals in the event of a breach of your unsecured protected health information.

Abide by the terms of this notice.

Notify you if we are unable to agree to a requested restriction.

Accommodate reasonable requests you may have to communicate information from your record by alternative means or at alternative locations.

Uses and Disclosures that Require Authorization. We will not use or disclose your protected health information under any of the following circumstances without first obtaining your authorization:

Psychotherapy notes. We will generally not use or disclose psychotherapy notes that contain your protected health information without your authorization. However, we may use or disclose psychotherapy notes:

To provide treatment to you;

For our own training programs involving mental health students;

To defend ourselves in any legal action or other proceeding brought by you;

In connection with an investigation by the Secretary of Health and Human Services or a health agency that has oversight over us;

If necessary to prevent a serious an imminent threat to the health or safety of any person or if otherwise required by law; and

To a coroner or medical examiner after your death.

Marketing. We will not use or disclose your protected health information for marketing purposes without your authorization, unless the marketing is in the form of a face-to-face communication or a promotional gift of nominal value. “Marketing” does not include communications to you for treatment, case management, or care coordination purposes or to describe a product or service that we provide.

Sale. We will not sell your protected health information without your authorization.

Examples Of How We Will Disclosure Your Information For Treatment, Payment And Health Operations

We will use information from your case record for treatment.

For example: Information obtained by your service provider will be recorded in your case record and used to determine the course of treatment and services that should work best for you. When a team of individuals are involved in your service delivery, we will share certain agreed upon components of your record. This is to ensure that the team can best meet your needs.

We will use your information in your case record for payment.

For example: A bill may be sent to you or a third-party payer i.e. an insurance company or a funder for a program. The information on or accompanying the bill may include information that identifies you, as well as your diagnosis (if applicable), procedures, and supplies used.

We will use information in your case record for continuous quality improvement of agency operations.

For example: Designated members of the staff may review information in your case record to assess the care and outcomes in your case and others like it. This information will then be used in an effort to improve the quality and effectiveness of the services we provide.

The supervisor of your service provider may review your case record as part of the supervisory process of the agency to ensure that your needs are being met and that agency policy and procedures are being followed.

Examples Of How We Will Disclosure Your Information For Purposes Other Than Treatment, Payment And Health Operations

Business Associates: There are some services provided in our organization through contracts with business associates. Examples include vendors, our auditors, our accrediting body, and other contract monitoring bodies. When these services are contracted, information in your case record may be disclosed to our business associate so that they can perform the job we’ve asked them to do, or they may have incidental access to information in your case record due to the proximity of case record information to their work. These agreements also include any observers or students that are in our organization for educational purposes. To protect information from your case record, however, we require the business associate to treat your information with the same degree of privacy and confidentiality that we do through a business associate agreement.

Notification and Communication with the Family: We may use or disclose information to notify or assist in notifying a family member, personal representative, or another person responsible for your care, your location, and general condition.

Abuse or Neglect: We may disclose information from your case record to a public authority that is authorized by law to receive reports of child or elder abuse or neglect. In addition, we may disclose information from your case record if we believe that you have been a victim of abuse, neglect, or domestic violence to the governmental entity or agency authorized to receive such information. In this case, the disclosure will be made consistent with the requirements of applicable federal and state laws.

Fundraising: We may send you information about our agency such as newsletters, fundraising events, etc. If you do not wish to receive these materials, please contact our Privacy Officer in writing and request that these fundraising materials not be sent to you. (Please see the end of this document for contact information)

Workers compensation: We may disclose information from your case record to the extent authorized by and to the extent necessary to comply with laws relating to workers compensation or other similar programs established by law.

Public health: As required or authorized by law, we may disclose information from your case record to public health or legal authorities charged with preventing or controlling disease, injury, or disability and to (i) report child abuse or neglect; (ii) track or report information concerning the quality, safety or effectiveness of a product regulated by the U.S. Food and Drug Administration; and (iii) report work-related injuries or illnesses or conduct medical surveillance of the workplace.

Correctional institution: Should you be an inmate of a correctional institution, we may disclose to the institution or agents thereof, information from your record necessary for your health and the health and safety of other individuals.

Law enforcement: We may disclose information from your record for law enforcement purposes as authorized or required by law.

Federal law makes provision for information from your record to be released to an appropriate health oversight agency, public health authority or attorney, provided that a work force member or business associate believes in good faith that we have engaged in unlawful conduct or have otherwise violated professional or clinical standards and are potentially endangering one or more patients, workers or the public. We may also disclose information from your record to a federal or state governmental agency that is responsible for oversight of the health care system or government benefit programs (such as Medicare or Medicaid) for purposes of audits, investigations, inspections, civil or criminal proceedings and other oversight activities.

Change of Ownership: If by chance, Catholic Charities is dissolved, all of our property becomes the property of Diocese of Kansas City-St. Joseph, Inc.

Research: We may use or disclose information from your record for research purposes in limited situations where additional steps have been taken to protect the privacy of your information, such as obtaining approval of an Institutional Review Board or a privacy board, or removing all of your identifying information.

Health and Safety: We may use or disclose information from your record to law enforcement personnel or other appropriate persons to the extent necessary to prevent or lessen a serious or imminent threat to the health or safety of a person or the public, and such use or disclosure is consistent with applicable law and ethical standards.

Military: If you are a member of the armed forces, we may disclose information from your record to military authorities as authorized or required by law.

Judicial and Administrative Proceedings: We may disclose information from your record pursuant to a court order, subpoena, discovery request or other lawful process in the course of any judicial or administrative proceeding.

Any use of your protected health information from your case record outside of this Notice will not occur without your written permission. If you provide us permission to use or disclose your protected health information, you may revoke that permission, in writing, at any time. If revoked, we will no longer use or disclose your protected health information for the specific purpose(s) contained in the authorization. However, your revocation will not apply to any uses or disclosures made prior to your revocation or in reliance on the authorization.

For More Information or to Report a Problem:

If you have questions and would like additional information, or if you believe your privacy rights have been violated, you have the right to file a formal, written complaint with us at the address below, or with the Secretary of the U.S. Department of Health & Human Services, Office of Civil Rights. We cannot and will not retaliate against you for filing a complaint. To file a complaint with us or to receive further information about our privacy practices or the content of this Notice, please contact:

Homeless Missourians Information System (HMIS)

Privacy and Security Notice

A written copy of this Policy is available to all who request it.
It is also available on this agency’s web site.

I. PURPOSE:

This notice describes the privacy policy of this agency. The policy may be amended at any time. We may use or disclose your information to provide you with services, and to comply with legal and other obligations. We assume that, by requesting services from our agency, you agree to allow us to collect information and to use or disclose it as described in this notice and as otherwise required by law.

The Homeless Missourians Information System (HMIS) was developed to meet a data collection requirement made by the United States Congress and the Department of Housing and Urban Development (HUD). Congress passed this requirement in order to get a more accurate count of individuals who are homeless and to identify the need for and use of different services by those individuals and families. We are collecting statistical information on those who use our services and report this information to a central data collection system.

In addition, many agencies in this area use HMIS to keep computerized case records. This information may be provided to other HMIS participating agencies. The information you may agree to allow us to collect and share includes: basic identifying demographic data, such as name, address, phone number and birth date; the nature of your situation and the services and referrals you receive from this agency. This information is known as your Protected Personal Information or PPI. All agencies using the HMIS share their data with other participating agencies, with the exception of Blind Service Providers. These blind agencies serve specific protected client populations, such as domestic abuse, sexual abuse, HIV/AIDS, alcohol and/or substance abuse, and mental health, and do not share client information.

GENERALLY, all personal information we maintain is covered by this policy. Generally, your personal information will only be used by this agency and other agencies to which you are referred for services.

Information shared with other HMIS agencies helps us to better serve our clients, to coordinate client services, and to better understand the number of individuals who need services from more than one agency. This may help us to meet your needs and the needs of others in our community by allowing us to develop new and more efficient programs. Sharing information can also help us to make referrals more easily and may reduce the amount of paperwork.

Maintaining the privacy and safety of those using our services is very important to us. Information gathered about you is personal and private. We collect information only when appropriate to provide services, manage our organization, or as required by law.

II. CONFIDENTIALITY RIGHTS:

This agency has a confidential policy that has been approved by its Board of Directors. This policy follows all HUD confidentiality regulations that are applicable to this agency, including those covering programs that receive HUD funding for homeless services. Separate rules apply for HIPPA privacy and security regulations regarding medical records.

This agency will use and disclose personal information from HMIS only in the following circumstances:
1. To provide or coordinate services to an individual.
2. For functions related to payment or reimbursement for services.
3. To carry out administrative functions including, but not limited to legal, audit, personnel, planning, oversight or management functions.
4. Databases used for research, where all identifying information has been removed.
5. Contractual research where privacy conditions are met.
6. Where a disclosure is required by law and disclosure complies with and is limited to the requirements of the law. Instances where this might occur are during a medical emergency, to report a crime against staff of the agency or a crime on agency premises, or to avert a serious threat to health or safety, including a person’s attempt to harm himself or herself.
7. To comply with government reporting obligations.
8. In connection with a court order, warrant, subpoena or other court proceeding where disclosure is required.

III. YOUR INFORMATION RIGHTS:

As a client receiving services at this agency, you have the following rights:
1. Access to your record. You have the right to review your HMIS record. At your request, we will assist in viewing the record within five working days.
2. Correction of your record. You have the right to request to have your record corrected so that information is up-to-date and accurate to ensure fairness in its use.
3. Refusal. Our ability to assist you depends on having certain personal identifying information. If you choose not to share the information we request, we reserve the right
to decline to provide you with services as doing so could jeopardize our status as a service provider.
4. Agency’s Right to Refuse Inspection of an Individual Record . Our agency may deny you the right to inspect or copy your personal information for the following reasons:
a. information is compiled in reasonable anticipation of litigation or comparable proceedings;
b. information about another individual other than the agency staff would be disclosed;

c. information was obtained under a promise of confidentiality other than a promise from this provider and disclosure would reveal the source of the information; or
d. information, the disclosure of which would be reasonably likely to endanger the life or physical safety of any individual.
5. Harassment. The agency reserves the right to reject repeated or harassing requests for access or correction. However, if the agency denies your request for access or correction, you will be provided written documentation regarding your request and the reason for denial. A copy of that documentation will also be included in your client record.
6. Grievance. You have the right to be heard if you feel that your confidentiality rights have been violated, if you have been denied access to your personal records, or if you have been put at personal risk, or harmed. Our agency has established a formal grievance process for you to use in such a circumstance. To file a complaint or grievance you should contact our Chief Operating Officer at: sjones@ccharities.com or (816) 221-4377.

IV. HOW YOUR INFORMATION WILL BE KEPT SECURE:

Protecting the safety and privacy of individuals receiving services and the confidentiality of their records is of paramount importance to us. Through training, policies, procedures and software, we have taken the following steps to make sure your information is kept safe and secure:
1. The computer program we use has the highest degree of security protection available.
2. Only trained and authorized individuals will enter or view your personal information.
3. Your name and other identifying information will not be contained in HMIS reports that are issued to local, state or national agencies.
4. Employees receive training in privacy protection and agree to follow strict confidentiality standards before using the system.
5. The server/database/software only allows individuals access to the information. Only those who should see certain information will be allowed to see that information.
6. The server/database will communicate using 128-bit encryption-an Internet technology intended to keep information private while it is transported back and forth across the Internet. Furthermore, identifying data stored on the server is also encrypted or coded so that it cannot be recognized.
7. The server/database exists behind a firewall-a device meant to keep hackers/crackers/viruses/etc. away from the server.
8. The main database will be kept physically secure, meaning only authorized personnel will have access to the server/database.
9. System Administrators employed by the HMIS and the agency support the operation of the database. Administration of the database is governed by agreements that limit the use of personal information to providing administrative support and generating reports using aggregated information. These agreements further insure the confidentiality of your personal information.

V. BENEFITS OF HMIS AND AGENCY INFORMATION SHARING:

Information you provide us can play an important role in our ability and the ability of other agencies to continue to provide the services that you and others in the community are requesting.

Allowing us to share your name results in a more accurate count of individuals and the services they use. Obtaining an accurate count is important because it can help us and other agencies:
1. Better demonstrate the need for services and the specific types of assistance needed in our area.
2. Obtain more money and other resources to provide services.
3. Plan and deliver quality services to you and your family.
4. Assist the agency to improve its work with families and individuals who are homeless.
5. Keep required statistics for state and federal funders, such as HUD.

VI. COMPLIANCE WITH OTHER LAWS

This agency complies with all other federal, state and local laws regarding privacy rights. Consult with an attorney if you have questions regarding these rights.

VII. PRIVACY NOTICE AMENDMENTS:

The policies covered under this Privacy Notice may be amended over time and those amendments may affect information obtained by the agency before the date of the change. All amendments to the Privacy Notice must be consistent with the requirements of the Federal Standards that protect the privacy of consumers and guide HMIS implementation and operation.

VIII. Web Site

We maintain a copy of the Privacy Notice on our web site at: www.catholiccharities-kcsj.org